AccountingLink

Comment Letters

30 September 2014

Comment Letter - FASB proposal to eliminate the concept of extraordinary items
In our comment letter, we supported the FASB's efforts to reduce the cost and complexity of financial reporting by eliminating the concept of extraordinary items. We believe the proposal would not affect the quality of information provided to financial statement users.

30 September 2014

Comment Letter - FASB proposal to simplify the measurement of inventory
In our comment letter, we said we do not support the FASB’s proposal to measure inventory at the lower of cost or net realizable value (LCNRV). For entities that use the last-in, first-out (LIFO) accounting method in declining price environments, we believe the Proposed Standard could increase the cost and complexity of preparing the financial statements and, in certain circumstances, reduce the usefulness of the information provided to users. We also said the continuing acceptability of the retail inventory method should be made more clear in a final standard.

14 July 2014

Comment Letter - Chapter 8: Notes to financial statements
In our comment letter, we supported the FASB’s objective of improving disclosure effectiveness in the notes to the financial statements by developing a framework the Board would apply when creating new disclosure requirements and evaluating existing ones. However, we are concerned that the proposed framework would actually perpetuate the significant expansion in disclosure that has occurred over the past few decades. We suggest changes to the framework, including the testing process, and recommend that the Board provide guidance on materiality and clearly distinguish between annual and interim requirements.

23 June 2014

Comment Letter - AICPA’s proposed statement on standards for attestation engagements
In our comment letter on the Proposed Statement on Standards for Attestation Engagements, Subject-Matter Specific Attestation Standards: Clarification and Recodification, we supported clarifying the standards in accordance with the clarity drafting conventions used in the proposed general attestation standard.

24 March 2014

Comment Letter - SEC 'Regulation A+' proposal
In our comment letter on the SECs proposed amendments to allow exempt public offerings under Regulation A of up to $50 million in a 12-month period, we recommend that the SEC consider additional opportunities to leverage disclosure requirements in existing SEC rules and regulations for registered offerings and scale those requirements for unregistered offerings conducted under Regulation A. We also encourage the SEC to clarify certain terminology and disclosure requirements in the proposal that could be difficult to interpret or apply.

12 February 2014

Comment Letter - Improving the transparency of audits
In our comment letter, we support identifying certain non-signing firms that have a significant role in an audit but do not support identifying the engagement partner in either the audit report or a public filing with the PCAOB because we don’t believe this would provide meaningful information to investors.

3 February 2014

Comment Letter - Crowdfunding
In our comment letter, we recommended that the SEC reconsider the financial reporting requirements it proposed for issuers that use a new crowdfunding exemption to raise up to $1 million a year by selling shares to investors over the internet. We said that the costs to comply with the proposed requirements in a crowdfunding offering and ongoing annual reporting would likely discourage use of the crowdfunding exemption, which was mandated by the Jumpstart Our Business Startups Act.

13 January 2014

Comment Letter - FASB proposal to eliminate development stage entity guidance
In our comment letter, we said we supported the FASB's efforts to reduce financial reporting cost and complexity by eliminating ASC 915 and its additional reporting requirements for development stage entities. However, we expressed our concern about how the proposed amendments could affect the way in which companies apply ASC 810's variable interest entity guidance and ASC 805's definition of a business when evaluating certain entities or operations that are in a development stage.

18 December 2013

Comment Letter - Proposed auditing standards on the auditor's report and the auditor's responsibilities regarding other information and related amendments
In our comment letter, we supported the PCAOB's effort to enhance the auditor’s report. However, we believe that certain elements of the proposal may be difficult to apply in practice. We also expressed concerns that the proposed requirements for other information would significantly expand the auditor’s performance responsibilities and result in increased liability risks for audit firms. In addition, while we support more transparency about auditor tenure, we believe that these disclosures can be made outside the auditor’s report. We recommended changes to the proposal to address these concerns.

2 December 2013

Comment Letter - Pay ratio disclosure
In our comment letter, we focus on certain aspects of the proposal, including sampling methods and pay ratio computation. We also make recommendations that we believe would reduce the cost and burden on issuers, promote disclosure and enhance comparability. The proposal would require most issuers to disclose the median annual compensation of all of their employees (excluding the principal executive officer) and the ratio of that amount to the annual compensation of their principal executive officer.

29 November 2013

Comment Letter - Statement on standards for attestation engagements
In our comment letter, we supported the AICPA’s objective of addressing concerns about the clarity, length and complexity of the attestation standards. Additionally, we commented on several ways to increase consistency between examinations and audit engagements.

30 October 2013

Comment Letter - SEC reproposal on credit risk retention
In our comment letter to the SEC on the credit risk retention reproposal it issued jointly with other agencies, we focus on the consolidation accounting ramifications. The proposal would require sponsors of certain asset-backed securitizations to retain at least 5% of the credit risk. The rule was mandated by the Dodd-Frank Wall Street Reform and Consumer Protection Act.

28 October 2013

Comment Letter - FASB proposed ASU on insurance contracts
In our comment letter, we encouraged the FASB and the IASB to work together to make their proposals more comparable. We also said the FASB needs to address certain issues before finalizing the guidance. Our most significant concerns relate to the proposed scope, discount rates and how changes in these rates would be recognized, recognition of changes in expected cash flows, revenue recognition, presentation and transition. We also encourage the Board to consider simplifying certain areas of the proposal to make it less costly to apply.

14 October 2013

Comment Letter - PCC proposal on applying variable interest entity guidance to common control leasing arrangements
In our comment letter, we said the Private Company Council’s proposal to permit private companies to avoid applying the variable interest entity (VIE) guidance to common control leasing arrangements when certain criteria are met would achieve the desired result of excluding the effects of a lessor’s financial position and operating results from a lessee’s financial statements. However, our experience suggests that the same objective may be achieved by clarifying the example in the Codification on the application of the VIE model.

24 September 2013

Comment Letter - FASB proposal on going concern uncertainties
In our comment letter, we said we support the FASB's effort to develop a going concern model that would require preparers of financial statements to assess going concern uncertainties and provide more timely footnote disclosures. However, we said certain issues need to be addressed before any final guidance on the subject is published.

20 September 2013

Comment letter - Definition of a public business entity
In our letter, we support the development of a single definition of a public business entity for future standard setting but say the proposed definition is complex and would be challenging to apply. We also note that the proposed definition would include many entities that aren't treated as public companies today and might differ from existing SEC rules, regulations and interpretations.

13 September 2013

Comment Letter - FASB/IASB proposal on leasing
While we continue to support the Boards’ efforts to improve the accounting for leases to provide greater transparency in financial reporting and address the needs of users of financial statements, we do not support the Proposal. We are unable to support the Proposal because it is unclear to us whether the ED would significantly improve the decision-useful information available to financial statement users. It also is unclear to us whether any of the perceived benefits to financial statement users would justify the costs and complexity of applying the ED.

12 September 2013

Comment Letter - SEC money market proposal
In our comment letter, we agree with the SEC that investments in money market funds should continue to meet the definition of cash equivalents under US GAAP if, as proposed, the SEC (1) requires a floating net asset value for certain funds and/or (2) permits redemption fees of up to 2% and suspensions of redemptions for up to 30 days if a fund fails to meet specified liquidity levels. We concur that under any of the proposed alternatives, entities should regularly evaluate changes in circumstances and whether an investment in a money market fund continues to meet the requirements of a cash equivalent.

26 August 2013

Comment Letter - Reporting discontinued operations
In our comment letter, we support the FASB’s objective to improve the usefulness of financial statements by highlighting significant strategic shifts in an entity’s business operations. However, we recommend that the FASB consider reporting discontinued operations in pro forma disclosure rather than on the face of the financial statements. We disagree with the Board’s decision to exclude from the definition of a discontinued operation the existing consideration of significant continuing operations and cash flows with the disposed component.

23 August 2013

Comment Letter - Accounting for certain receive-variable, pay-fixed interest rate swaps, a proposal of the Private Company Council
We appreciate the opportunity to comment on the Private Company Council’s and Financial Accounting Standards Board’s (FASB or Board) Proposed Accounting Standards Update, Accounting for Certain Receive-Variable, Pay-Fixed Interest Rate Swaps (the proposed Update). Our letter supports the Board’s overall objective of simplifying hedge accounting for interest rate swaps that allow companies to economically convert variable-rate borrowings to fixed-rate borrowings. Although we believe both of the approaches described in the proposed Update would support the Board’s overall objective, we support the simplified hedge accounting approach because it is more aligned with existing GAAP and has more widespread application.

23 August 2013

Comment Letter - Accounting for goodwill, a proposal of the Private Company Council
In our comment letter, we acknowledge the PCC's observation that certain users of private company financial statements may ignore goodwill and goodwill impairment losses in their analysis of a private company’s financial condition and operating performance. However, we challenge whether this is sufficient justification for amending the goodwill accounting model for private companies. We believe that any change to the goodwill accounting model should be fundamentally consistent with the conceptual underpinnings in US GAAP in addition to being convenient to apply.

23 August 2013

Comment Letter - Accounting for identifiable intangible assets in a business combination, a proposal of the Private Company Council
Our comment letter acknowledges the PCC's observation that some users of private company financial statements believe that distinguishing certain intangible assets from goodwill may not provide decision-useful information. However, we challenge whether this is sufficient justification for amending themodel for accounting for the acquisition of intangible assets in a business combination.

25 July 2013

Comment Letter - Technical corrections and improvements related to glossary terms
Our comment letter highlights proposed changes to ASC glossary terms that could have significant effects on existing practice, may have unintended consequences and/or may be unclear to stakeholders.

8 July 2013

Comment letter - PCAOB reproposal on related party transactions
In our comment letter, we express our support for the reproposal. We have one concern with the reproposal regarding the proposed effective date. The Board proposes that the reproposal would be effective, subject to approval by the Securities and Exchange Commission (SEC), for audits of financial statements for fiscal years beginning on or after 15 December 2013. We believe that this effective date is operational only if the SEC approves the reproposal before 31 October 2013.

21 June 2013

Comment Letter - Private company decision-making framework
In our comment letter, we support the use of a framework to help the Private Company Council (PCC) and the FASB make decisions about whether and when to provide alternatives for private companies under US GAAP. We believe that providing relief to private companies by using practical expedients for recognition and measurement alternatives, reducing disclosures and modifying transition requirements could help the PCC and the Board meet their objective of providing relevant information in private company financial statements in a more cost-effective manner while preserving the same fundamental basis of accounting for public and private companies.

31 May 2013

Comment letter - FASB proposal on credit losses of financial instruments 
In our comment letter, we urge the FASB to work with the IASB to converge their proposals to require more timely recognition of credit losses than under today’s incurred loss model. We note that the FASB could accomplish its goal of timelier recognition of losses by lowering the threshold for recognizing losses. We also recommend that the FASB exclude debt securities and trade, lease and reinsurance receivables from its proposal.

31 May 2013

Comment Letter - FASB proposal to defer the effective date of certain disclosures for nonpublic employee benefit plans
In our comment letter, we support the FASB’s proposal to indefinitely defer the requirement for a nonpublic employee benefit plan to disclose quantitative information about the significant unobservable inputs used in measuring the fair value of investments held in the plan sponsor’s nonpublic equity securities. We also suggest the Board clarify whether an employee benefit plan that meets the definition of a nonpublic employee benefit plan in the proposal would be considered a nonpublic entity under ASC 820-10-50-2F and therefore would not be required to make certain other disclosures.

28 May 2013

Comment letter - PCAOB’s proposed framework for reorganizing its auditing standards
In our comment letter, we say that we do not support the proposed reorganization at this time. While we agree that reorganizing the standards may help users navigate them more easily, we disagree with the PCAOB’s assertion that the proposed reorganization would help avoid confusion between the PCAOB’s standards and the recently reorganized standards of the ASB or that the proposed structure would facilitate comparison of PCAOB and IAASB standards.

15 May 2013

Comment letter - FASB proposal on classification and measurement of financial instruments
In our comment letter, we say that while the FASB proposal on classification and measurement of financial instruments would represent a big step toward convergence, we do not support finalizing it in its current form. We believe the proposal may inappropriately require too many financial instruments, including certain common debt instruments, to be measured at fair value with changes in fair value recognized in net income. We are also concerned that certain provisions of the proposal could be interpreted in different ways and lead to diversity in practice. However, we believe the FASB can make specific changes and clarifications that will improve the proposal’s operability.

29 March 2013

Comment letter - FASB proposal on effective control for transfers with forward agreements to repurchase assets and accounting for repurchase financings
In our letter, we generally agree that repurchase-to-maturity agreements with characteristics described in the FASB’s proposal should be accounted for as secured borrowings. However, we also recommend that the FASB more broadly re-examines the accounting for the derecognition of financial assets.

22 January 2013

Comment letter - FASB proposal to clarify the scope of a fair value disclosure for nonpublic entities
We agreed with the FASB’s proposal to amend ASC 825 to clarify that nonpublic entities are not required to disclose the fair value hierarchy level for items that are not measured at fair value on the statement of financial position but for which fair value is disclosed. We also recommended that the FASB subsequently address the overlap in ASC 825 and ASC 820 regarding this disclosure requirement as well as situations where terms such as “nonpublic entity” have multiple definitions in the glossary of the Codification.

17 January 2013

Comment letter - COSO’s revised internal control framework and compendium of approaches and examples
We support COSO’s efforts to update its 1992 Internal Control – Integrated Framework to reflect changes in the business and operating environment and believe the Compendium will provide users with helpful guidance. In our comment letter, we expressed our support for COSO’s efforts to update and enhance the framework to enable users to better develop, implement and monitor systems of internal control. We also expressed certain concerns and suggested modifications to the revised framework and compendium, including, among others, enhancing the guidance related to an organization’s assessment of the effectiveness of its internal controls; modifying its definitions of deficiencies and major deficiencies; providing guidance about the precision of management review controls; and providing additional guidance on the application of the Revised Framework to smaller organizations.

14 January 2013

Comment letter - CFTC proposal on enhancing customer protection
In our comment letter on the CFTC’s proposal, Enhanced Protections Afforded Customers and Customer Funds Held by Futures Commission Merchants and Derivatives Clearing Organizations, we questioned the need for a requirement that auditors of FCMs be registered with and have undergone an examination by the PCAOB. We also said the proposal that deficiencies noted in such an examination must have been remediated to the satisfaction of the PCAOB within three years of a report would be unworkable. Instead, we recommended that the CFTC consider seeking statutory change to make auditors of FCMs subject to the registration and inspection requirements of the PCAOB or require that auditors of FCMs be registered with and subject to inspection by the PCAOB, similar to the requirement for auditors performing surprise examinations of investment advisers under the SEC's Custody Rule.

19 December 2012

Comment letter - FASB proposal to limit the scope of disclosures about offsetting assets and liabilities
Our comment letter agrees with the FASB's proposal to limit the scope of ASU-2011-11 to derivatives, repurchase agreements and reverse repurchase agreements, and securities borrowing and securities lending transactions. We also challenge whether ASU-2011-11's collateral disclosures are needed for instruments in the Proposed Update's scope that are not offset on the balance sheet.

30 November 2012

Comment letter - FASB discussion paper on disclosure framework
Our comment letter supports the FASB’s decision to address disclosure effectiveness and to develop a framework to promote consistent decisions about disclosure requirements. However, we believe disclosure overload exists and therefore urge the FASB to make reducing disclosure requirements a priority of the project and to limit new disclosure requirements until the project is completed.

27 November 2012

Comment Letter - More implementation guidance needed in a final revenue standard
In a recent comment letter, we applauded the FASB and the IASB for their commitment to smooth implementation of a final revenue standard. However, we recommended that the Boards provide additional implementation guidance to avoid diversity in practice.

31 October 2012

Comment letter - FASB staff recommendations for a private company decision-making framework
In our comment letter, we support the use of a framework to help the Private Company Council (PCC) and the FASB make decisions about whether and when to modify the requirements of accounting standards for private companies. We explain why we believe recognition and measurement generally should be the same for private and public companies, and why the Board should focus on disclosure and transition relief for private companies.

15 October 2012

Comment Letter - FASB proposal to present items reclassified out of AOCI
Our comment letter supports the FASB’s proposal to require the presentation of items reclassified out of AOCI in the notes to the financial statements rather than on the face of the financial statements as previously proposed. We are also supportive of the Board’s decision to not require breakout and disclosure of amounts included in net income for items that are not reclassified into net income in their entirety (e.g., items that are capitalized on reclassification out of AOCI and recognized in income at a later date). However, we believe the usefulness of disclosures that are proposed is compromised by the lack of conceptual basis for OCI and related reclassifications.

1 October 2012

Comment Letter - The liquidation basis of accounting
We support the Board’s efforts to provide guidance on how and when to apply the liquidation basis of accounting. This Proposed Update would promote consistency in how and when entities apply the liquidation basis of accounting and would provide information that is more relevant to users of the financial statements.

25 September 2012

Comment Letter - Proposed ASU on liquidity risk and interest rate risk disclosures
Our comment letter explains why we do not support finalizing the FASB proposal to require all entities to provide disclosures about their exposures to liquidity risk and interest rate risk. We believe that many of the proposed disclosures are redundant given current SEC reporting requirements. Additionally, we believe that nonpublic and not-for-profit entities should be exempted from the proposed update because we don't believe the incremental benefits outweigh the costs of compliance.

11 September 2012

Comment Letter - Section 108 of the JOBS Act - Regulation S-K Review
Our comment letter recommends that the SEC broaden the scope of its review and eliminate redundant or outdated disclosures for all issuers. We also suggest that informational disclosures that are not specific to a reporting period should appear in a company profile and that only new information should be included in periodic reports.

31 May 2012

Comment Letter - Proposed PCAOB auditing standard on related parties
Our comment letter supports the Board’s efforts to update the requirements of AU Section 334, Related Parties, and adopt other proposed amendments. We believe these actions have the potential to improve audit quality. However, we have some concerns with certain aspects of the proposal that are addressed in our letter.

30 April 2012

Comment Letter - PCAOB proposal on rules and form amendments related to broker dealers
Our letter to the PCAOB generally supports the proposed changes to the Board’s rules and forms to conform to the Dodd-Frank Act. The proposed amendments include references to audits and auditors of brokers and dealers in relevant Board rules and forms and other technical changes.

24 April 2012

Comment Letter - Testing indefinite-lived intangible assets for impairment
In our comment letter, we support the Board’s efforts to reduce the cost and complexity of performing the impairment test. We also say the Board should consider adding implementation guidance on how to assess a mix of positive and negative evidence affecting the significant inputs used to determine fair value.

30 March 2012

Comment Letter - Exposure draft of Internal Control - Integrated Framework
Our comment letter supports the Committee of Sponsoring Organization’s efforts to help organizations effectively and efficiently develop and maintain systems of internal control by enhancing the 1992 framework to reflect changes in the business and operating environment since its development. We also outline our concerns about the proposal and suggest modifications to clarify a number of areas in the proposed framework and to make it more helpful to users.

13 March 2012

Comment Letter - Joint re-proposal on revenue recognition
We continue to support the Boards’ intention to develop a converged revenue recognition standard for IFRS and US GAAP. While we believe the Boards have made significant progress addressing the concerns raised by constituents about their 2010 exposure draft, more work needs to be done to enable consistent application.

29 February 2012

Comment Letter - PCAOB proposal on communications with audit committees
Our letter supports the PCAOB's efforts to enhance communication with audit committees and provide additional information to help audit committees fulfill their oversight responsibilities. We believe the proposal will help enhance audit quality. Our comment letter also offers suggestions to improve the final standard.

15 February 2012

Comment Letter - Consolidation: Principal vs. agent analysis
Our comment letter supports for the Board’s efforts to more closely align the guidance in US GAAP with IFRS and we believe the proposed principal-agent guidance would alleviate many concerns investors in the asset management industry had with FASB Statement No. 167. Given that the proposal would substantially reduce the differences between the two consolidation models in US GAAP, we also encourage the Board to consider moving toward a single model.

15 February 2012

Comment Letter - Investment companies
Our comment letter supports the objective of amending the investment company definition to clarify whether an entity is within the scope of Topic 946. However, we believe more outreach with preparers and users is critical to determine whether the proposed changes are appropriate and respond to user needs.

15 February 2012

Comment Letter - Proposed ASU on investment properties
Our comment letter opposes creating specialized accounting for investment property entities and suggests that existing diversity in practice among real estate entities would be better addressed by refining the definition of and accounting by an investment company. We believe that a single set of criteria for investment entities that measure their investments at fair value with all changes in fair value recognized in net income would be preferable.

9 January 2012

Comment Letter - PCAOB proposal to disclose engagement partner and certain other participants in audits
In our letter to the PCAOB on its proposal to improve the transparency of audits by disclosing the engagement partner and certain other participants in audits, we support additional disclosure of other participants but suggest modifications that would make the information more useful to users of financial statements and simpler for firms to compile.

6 January 2012

Comment letter - FAF proposal to establish Private Company Standards Improvement Council
Our comment letter supports the Financial Accounting Foundation’s (FAF) plan to establish a new council that would identify, propose, deliberate and formally vote on specific improvements to US accounting standards for private companies, subject to ratification by the FASB. However, we believe that the criteria for determining whether and when exceptions or substantive modifications to US GAAP for private companies are warranted must be developed judiciously to minimize the risk that the process will result in two sets of US accounting standards.

13 December 2011

Comment Letter - Technical corrections
Our comment letter agrees that most of the proposed changes would not be expected to have a significant effect on current accounting practice. However, we believe that several of the proposed amendments would have significant implications for some entities and those proposals should either be revised or transition should be provided.

21 November 2011

Comment letter - Deferral of effective date for amendments to the presentation of reclassifications of Items out of AOCI in ASU 2011-05
Our comment letter supports the FASB’s proposal to defer the effective dates of the requirement in Accounting Standards Update 2011-05 to present on the face of the financial statements the effects of reclassification adjustments out of accumulated other comprehensive income on the components of net income and other comprehensive income. We believe the deferral should be permanent.

18 November 2011

Comment letter - PCAOB concept release on auditor independence and audit firm rotation
In our letter, we affirm our view that auditor independence, objectivity and professional skepticism are of paramount importance, but state that we do not believe mandatory audit firm rotation would improve audit quality or auditor skepticism. In fact, we believe it would harm corporate governance, investor interests and the objective of maintaining a robust, highly skilled independent accounting profession performing high-quality audits. In addition, we outline our ideas on measures that should be considered by the PCAOB to achieve its objectives and our views on other ideas presented in the concept release.

18 November 2011

Summary of key messages - PCAOB concept release on auditor independence and mandatory firm rotation
This document provides a summary of Ernst & Young's key messages to the PCAOB as expressed in our comment letter on the concept release on auditor independence and audit firm rotation.

14 October 2011

Comment Letter - Accounting and financial reporting for pensions - an amendment of GASB Statement No. 27
Our comment letter supports the Board’s effort to improve pension accounting and reporting for governmental entities. However, we recommend that the Board require the use of a single method for developing the discount rate and suggest that it be based on yields on high-quality fixed income investments. We also recommend that the Board require the use of the projected unit credit actuarial cost method (PUCM), rather than the individual entry age actuarial cost method.

6 October 2011

Comment Letter - Retrospective review of existing regulations
Our comment letter to the SEC strongly supports the SEC’s initiative to improve the retrospective review of its regulations.

30 September 2011

Comment Letter - Concept release on possible revisions to PCAOB standards related to reports on audited financial statements
Our comment letter to the PCAOB supports responsible change to the auditor reporting model and outlines a possible approach to revising the auditor’s reporting model.

12 September 2011

Comment Letter - PCAOB’s proposed attestation standards for broker-dealer engagements
Our comment letter support the PCAOB’s proposed effective date and recommends that the PCAOB (1) provide guidance for auditors when evaluating material non-compliance with the Financial Responsibility Rules, (2) provide guidance on specific engagement quality reviewer procedures to be performed in the contemplated engagements and (3) clarify certain concepts included in the proposing release and related existing PCAOB standards.

12 September 2011

Comment Letter - Proposed auditing standard related to auditing supplemental information
Our comment letter to the PCAOB supports its effort to update its interim standard and we agree that an “in relation to” report is the appropriate level of reporting for supplemental information. However, we state in our letter that we believe some of the enhancements are not consistent with the “in relation to” reporting model that was retained in the proposed standard.

26 August 2011

Comment Letter - Proposed rule on broker-dealer reports
Our comment letter on the SEC's proposed rule on broker-dealer reports generally supports the proposal because we believe it is a necessary step in updating broker-dealer financial reporting. We also believe the SEC's proposal would provide the clarity necessary for the PCAOB to develop and adopt appropriate auditing and reporting standards for auditors of registered broker-dealers.

8 August 2011

Comment Letter - Proposed rules for nationally recognized statistical rating organizations
Our comment letter discusses the SEC’s Nationally Recognized Statistical Rating Organizations (NRSRO) rule proposal that would include provisions requiring the issuer or underwriter of any asset-backed security (ABS) to make publicly available the findings and conclusions of third-party due diligence reports they obtain.

1 August 2011

Comment Letter - Credit risk retention
Our comments on this proposal are limited to (1) the possible consolidation accounting ramifications of the horizontal risk retention option and (2) the proposed agreed upon procedures report from an independent public accounting firm that would be required for a sponsor using a representative sample as a method to retain risk in the securitized assets.

28 July 2011

Comment Letter - Workplan for incorporating IFRS into the financial reporting system for US issuers
Our comment letter to the SEC supports the approach described in the Staff Paper. We believe that it is a thoughtful and balanced way of moving closer to achieving the ultimate goal of a single set of high-quality globally accepted accounting standards.

6 June 2011

Comment Letter - Testing goodwill for impairment
Our comment letter supports the Board's efforts to reduce the cost and complexity of performing the first step of the goodwill impairment test. We also say the Board should consider adding implementation guidance and consider allowing the use of a qualitative screen for the impairment testing of indefinite-lived intangible assets.

26 May 2011

Comment Letter - Omnibus Statement on Auditing Standards - 2011
Our comment letter provides our views on the proposed Omnibus SAS. We generally support the proposal.

29 April 2011

Comment Letter - Clearing agency standards for operation and governance
Our comment letter supports the SEC proposal to allow a non-US- based clearing agency to post on its website audited financial statements prepared in accordance with either US GAAP or IFRS as issued by the IASB, without reconciliation to US GAAP.

27 April 2011

Comment Letter - Balance sheet offsetting
Our comment letter recommends that the Boards should consider adopting a model that retains the existing exceptions in US GAAP for repo and reverse repo agreements and certain derivative contracts subject to master netting arrangements. We believe that adoption of the US GAAP exceptions would be a pragmatic solution to achieve convergence in offsetting.

25 April 2011

Comment Letter - Selected issues about hedge accounting
Ernst & Young is supportive of the Boards' efforts to arrive at a converged solution to accounting for hedging transactions. On balance, we support the overall direction of the IASB’s proposal to align hedge accounting with an entity’s risk management activities.

1 April 2011

Comment Letter - Financial instruments - impairment
Our comment letter provides our views on the Boards' efforts to arrive at a converged solution to accounting for credit impairment under IFRS and US GAAP. We believe that there are a number of operational issues with the joint approach that will require the development of additional guidance and will benefit from robust field testing.

2 March 2011

Comment Letter - Conflict minerals
Our comment letter brings up various concerns and issues related to the proposal as currently drafted.

31 January 2011

Comment Letter - Disclosure of payments by resource extraction issuers
Our comment letter notes that the cost and time required to obtain assurance on the Resource Extraction Issuers Exhibit might outweigh the benefits to users.

31 January 2011

Comment Letter - FASB’s discussion paper, effective dates and transition methods
Our comment letter suggests that the FASB further delay the effective date of the various joint projects because preparers will need a good deal of time to make the necessary changes prior to adoption.

14 January 2011

Comment Letter - FASB proposal on repurchase agreements
Our comment letter provides our views on the FASB's Proposed Accounting Standards Update, Reconsideration of Effective Control for Repurchase Agreements. We believe the proposed amendments represent an improvement and simplification to the accounting for these arrangements.

14 January 2011

Comment Letter - Reconsideration of effective control for repurchase agreements
Our comment letter supports the FASB's proposal to amend the accounting model for repurchase agreements and similar arrangements that both entitle and obligate the transferor to repurchase financial assets before their maturity. We believe the proposed amendments represent an improvement and simplification to the accounting for these arrangements.

21 December 2010

Comment Letter - Deferring the effective date of disclosures about troubled debt restructurings
Our comment letter supports the proposal to defer the effective date of disclosures about troubled debt restructurings in ASU 2010-20 to align with the effective date of the Proposed Accounting Standards Update, “Clarifications to Accounting for Troubled Debt Restructurings by Creditors.

13 December 2010

Comment Letter - FASB proposal on troubled debt restructurings
Our comment letter provides our views on the FASB proposal related to the accounting for troubled debt restructuring.

10 December 2010

Comment Letter - Standard setting timetable for MoU projects
This comment letter provides our views on the pace of accounting changes resulting from the joint projects.

1 December 2010

Comment Letter - FASB preliminary views on insurance contracts
Our comment letter agrees with the fundamental objective of the Boards to develop a single set of high quality global accounting and financial reporting standards. However, we have significant concerns about some of the features of the proposed measurement model and believe these must be resolved before a standard on insurance contracts can be finalized.

1 December 2010

Comment Letter - Joint FASB/IASB proposal on leases
Our comment letter supports the Boards’ efforts to improve lease accounting. However, there are key conceptual and application issues related to the proposals in the exposure draft that must be addressed in order for these proposals to be operational.

15 November 2010

Comment Letter - Issuer review of assets in offerings of asset-backed securities
Our comment letter discusses the nature of procedures that accountants have historically performed related to ABS offerings. Analysis has shown that investors, as well as underwriters and issuers, in many cases did not adequately understand the risks of the assets underlying the ABS. We believe that Sections 945 and 932 of the Dodd-Frank Wall Street Reform Act were intended to mitigate these shortcomings by enhancing the understanding of the assets underlying the ABS.

12 November 2010

Comment Letter - Application of the “failure to supervise” provision of the Sarbanes-Oxley Act of 2002
Our comment letter provides our views on the PCAOB Concept Release with regard to sanctions on registered public accounting firms for failing reasonably to supervise.

3 November 2010

Comment Letter - IASB Staff Draft on consolidated financial statements
Our comment letter supports the objective of developing a single consolidation principle, based on control, applicable to all entities. For successful implementation of the principle, we agree there should be a clear definition of control which incorporates the related concept of power. Specifically, we agree with and support a control principle as articulated in the Staff Draft. However, while we agree with the control principle articulated in the Staff Draft, we believe that the application guidance in the Staff Draft is internally inconsistent with this control principle. In particular, we believe the application guidance for potential voting rights and de facto control is inappropriate.

28 October 2010

Comment Letter - Disclosure about an employer’s participation in a multiemployer plan
Our comment letter supports the FASB's effort to enhance multiemployer plan disclosure requirements to enable users to better understand risks associated with participation in a multiemployer plan. We also believe that the proposed disclosure requirements should be streamlined to require the most relevant decision-useful information.

30 September 2010

Comment Letter - Statement of comprehensive income
Under the proposed model, an entity would be required to report total comprehensive income and its components in two parts, net income and other comprehensive income (OCI), in a continuous statement of comprehensive income. Our comment letter notes that we find it difficult to evaluate the proposed changes while there are no clear underlying principles for the recognition of OCI or the reclassification of such items to net income.

17 September 2010

Comment Letter - Disclosure of certain loss contingencies
While significantly improved over the first exposure draft in 2008, our comment letter expresses concerns regarding whether the loss contingency proposal is operational and would achieve the FASB's disclosure objectives.

14 September 2010

Comment Letter - Blue Ribbon Panel proposal on private company accounting
This comment letter provides our views to the "Blue Ribbon" Panel on standard setting for private companies.

13 September 2010

Comment Letter - PCAOB proposed auditing standard–confirmation
Our comment letter provides our views on the PCAOB's proposed rule on audit confirmations.

10 September 2010

Comment Letter - Financial instruments and derivative/hedging activities
This comment letter provides our views on the FASB's proposal on the accounting for financial instruments and derivative instruments and hedging activities.

7 September 2010

Comment Letter - Amendments to common fair value measurement and disclosure requirement
We are supportive of the Boards’ efforts to develop common requirements for measuring fair value and disclosing information about fair value measurements under US GAAP and IFRS. However, our comment letter identifies several potentially significant changes to practice that give us concern.

10 August 2010

Comment Letter - Disclosure of Certain Loss Contingencies
This comment letter requests an extension of comment letter due date for the FASB's re-proposal on contingencies.

16 July 2010

Comment Letter - Conceptual framework for financial reporting: the reporting entity
Our comment letter supports the addition of a project on the reporting entity to the Boards’ agenda. However, we have concerns with the description of the reporting entity and the ability to apply the definition in practice.

1 June 2010

Comment Letter - IRS proposal to require tax return disclosure of uncertain tax positions
This comment letter provides our views on the IRS proposal to require tax return disclosure of certain uncertain tax positions.

27 May 2010

Comment Letter - Communications with Audit Committees
Our comment letter provides our views on the PCAOB's proposal on communications to audit committees.

1 March 2010

Comment Letter - PCAOB Reproposed Risk Assessment Standards
This comment letter provides our views on the PCAOB's proposed risk assessment standards.

27 January 2010

Comment Letter - Proposed ASU on subsequent events
This comment letter provides our views on the FASB's proposal on subsequent events.

24 November 2009

Comment Letter - Proposed Rules on Auditing Standard No. 7, Engagement Quality Review
This comment letter provides our views on the PCAOB's re-proposal on engagement quality review.

11 November 2009

Comment Letter - Proposed ASU, "Derivatives and Hedging (Topic 815)– Scope Exception Related to Embedded Credit Derivatives"
This comment letter provides our views on FASB's proposal on embedded credit derivatives and scope exception.

14 October 2009

Comment Letter - Proposed ASU: Improving disclosures about fair value measurements
This comment letter provides our views on the FASB's proposal to improve disclosures related to fair value.

14 October 2009

Comment Letter - Proposed ASU: Oil and gas reserve estimation and disclosure
This comment letter provides our views on the FASB's proposal to improve oil and gas reserve estimation disclosures.

16 September 2009

Comment Letter - SEC’s proposed proxy disclosures
This comment letters expresses our views on the SEC's proposal to improve proxies.

9 September 2009

Comment Letter - Concept release on requiring the engagement partner to sign the audit report
Our comment letter provides Ernst & Young views on the PCAOB concept release on engagement partner sign-off of an audit report.

24 August 2009

Comment Letter - FASB Exposure Draft on disclosures about the credit quality of financing receivables and the allowance for credit losses
This comment letter provides our views on the FASB proposal on the allowance for credit losses and the credit quality of financing receivables.

19 July 2009

Comment Letter - Preliminary views on leases
Our comment letter provides our views on the joint IASB/FASB Discussion Paper, Leases: Preliminary Views.

19 June 2009

Comment Letter - Preliminary views on revenue recognition in contracts with customers
This comment letter provides our views on the IASB/FASB Preliminary Views on revenue recognition.

12 June 2009

Comment Letter - FASB Staff Position FIN 48-d: Application guidance for pass-through entities
This comment letter provides our views on a proposed FSP on FIN 48 application guidance.

5 June 2009

Comment Letter - Concept release on possible revisions to the PCAOB’s standard on audit confirmations
This comment letter provides our views on PCAOB's Concept Release on audit confirmations.

3 June 2009

Comment Letter - Proposed FSP FAS 157-f on measuring liabilities under FAS 157
This comment letter provides our views of the proposed FSP on measuring liabilities under FASB Statement No. 157.

15 May 2009

Comment Letter - FASB proposal related to various technical corrections
This comment letter provides our views on certain technical corrections proposed by the FASB.

15 April 2009

Comment Letter - FASB and the IASB discussion paper on financial statement presentation
This comment letter provides our views on its discussion document related to financial statement presentation.

15 April 2009

Comment Letter - PCAOB proposed auditing standard on engagement quality reviews
This comment letter provides our views on the PCAOB's revised proposal on engagement quality reviews.

3 April 2009

Comment Letter - Questions raised by Financial Crisis Advisory Group
This comment letter provides our views to questions raised by the Financial Crisis Advisory Group (FCAG) regarding accounting and reporting matters related to the financial crisis.

4 March 2009

Comment Letter - SEC proposed Roadmap for the potential use of IFRS by US registrants
Our comment letter provides Ernst & Young's views on the potential adoption of IFRS by US registrants.

25 February 2009

Comment Letter - Proposed amendments to the disclosure requirements in FASB Statement No. 107, Disclosures about Fair Value of Financial Instruments
This comment letter expresses our views on the proposed FSP to amend FAS 107 to require fair value disclosures in interim financials.

18 February 2009

Comment Letter - Proposed PCAOB Auditing Standards: Auditor's assessment of and response to risk
This comment letter provides our views on the proposed PCAOB proposal on risk assessment.

13 February 2009

Comment Letter - Proposed Statement 133 Implementation Issue No. C22: Scope exception for embedded credit derivative
The comment letter provides our views on DIG Issue C 22 on embedded credit derivatives.

23 January 2009

Comment Letter - Proposed FSP FAS 144-d, amending the criteria for reporting a discontinued operation
This comment letter provides our views on the FASB's proposed FSP related to discontinued operations.

15 January 2009

Comment Letter - Proposed FSP amending FAS 107-a-disclosure requirements related to financial instruments
This comment letter provides our views on the proposed FASB FSP to amend the disclosure requirements for financial assets under FAS 107.

14 January 2009

Comment Letter - FASB Accounting Standards Codification
This comment letter presents our views on the proposed FASB codification.

13 January 2009

Comment Letter - Proposed FSP FAS 141(R)-a-Preacquisition contingencies in business combinations
This comment letter presents our views on the proposed FASB FSP on pre-acquisition contingencies in business combinations.

6 January 2009

Comment Letter - Proposed Accounting Standards Update, "Amendments to Statement 167 for Certain Investment Funds"
This comment letter provides our views on the FASB's proposal to defer FAS 167 for certain entities.

8 December 2008

Comment Letter - FASB Exposure Draft on going concern
This comment letter provides our views on the FASB proposal on going concern.

8 December 2008

Comment Letter - FASB Exposure Draft on subsequent events
The comment letter provides our views on the FASB proposal on subsequent events.

5 December 2008

Comment Letter - FASB and IASB Exposure Drafts on earnings per share
This comment letter provides our views of both the FASB and IASB proposals on the calculation of earnings per share.

2 December 2008

Comment Letter - FASB proposed FSP FIN 48-c
The comment letter provides our views on the FASB proposed FSP to further delay the application of FIN 48 for non-public entities.

4 November 2008

Comment Letter - Proposed amendment to FASB Statement 140
This comment letter provides our views on the FASB's proposed amendment to Statement 140 related to transfers of financial assets.

30 October 2008

Comment Letter - Proposed Amendment to FIN 46(R) - Consolidation of variable interest entities
This comment letter provides our views on the FASB's proposed amendment to FIN 46(R) on consolidation of variable interest entities.

17 October 2008

Comment Letter - Proposed FSP FAS 140-e and FIN 46(R)-e -Disclosures about transfers of financial assets and interests in variable interest entities
This comment letter provides our views on the FASB's proposed FSP relating to disclosures about transferred assets and interests in variable interest entities.

3 October 2008

Comment Letter - IASB/FASB Joint Conceptual Framework Project - DP/ITC on Reducing Complexity in Reporting Financial Instruments
This comment letter provides our views on the joint IASB/FASB Discussion paper on reducing complexity in financial instruments.

2 October 2008

Comment Letter - IASB/FASB Joint Conceptual Framework Project - PV on the Reporting Entity
This comment letter provides our views on the joint FASB/IASB discussion document on the conceptual framework.

26 September 2008

Comment Letter - IASB/FASB Joint Conceptual Framework Project - Exposure Draft - Chapter 1 and Chapter 2
This comment letter provides our views on the Joint FASB/IASB Exposure Draft on Chapters 1 and 2 of the conceptual framework.

3 September 2008

Comment Letter - SEC proposal on modernization of oil and gas reporting requirements
This comment letter provides our views on the SEC's proposal to modernize oil and gas reporting requirements.

19 August 2008

Comment Letter - FASB Exposure Draft on Hedging
This comment letter provides our views on the FASB's proposal on hedging activities.

14 August 2008

Comment Letter - COSO guidance on monitoring internal control systems
This comment letter provides our views on the Committee of Sponsoring Organizations (COSO) guidance on monitoring internal control systems.

31 July 2008

Comment Letter - FASB proposed statement to significantly expand disclosures for loss contingencies
This comment letter provides our views on the FASB's proposal to significantly expand disclosures for loss contingencies.

31 July 2008

Comment Letter - SEC proposed rule on XBRL
This comment letter provides our views on the SEC's proposal to modernize oil and gas reporting requirements.

10 July 2008

Comment Letter - FASB Request for Additional Comments NFP: M&A
This comment letter provides our views on the FASB's proposal on mergers and acquisition of not-for-profit entities.

30 June 2008

Comment Letter - Proposed FSP FAS 133-b and FIN 45-c on disclosures about credit derivatives
This comment letter provides our views on the FASB's proposed FSP on disclosures about credit derivatives.

27 June 2008

Comment Letter - Recommendations of the Treasury Advisory Committee on the accounting and auditing profession
This comment letter provides our views on the Treasury Advisory Committee on the accounting and auditing profession.

13 June 2008

Comment Letter - Proposed FASB FSP ARB 43-a-physical inventories held for trading
This comment letter provides our views on the FASB's proposed FSP on physical inventories held for trading.

30 May 2008

Comment Letter - FASB preliminary views: Financial instruments with characteristics of equity
Our comment letter supports a joint FASB and IASB project to comprehensively consider the model for distinguishing between liabilities and equity as well as the related measurement and financial statement presentation issues. We tentatively support the “basic ownership” approach from the three models described in the PV for various reasons, including its perceived simplicity.

12 May 2008

Comment Letter - PCAOB Proposal on Engagement Quality Review
This comment letter provides our views on the PCAOB's proposal on engagement quality review.

5 May 2008

Comment Letter - EITF07-05 Draft Abstract-Determining whether an instrument (or embedded feature) is indexed to an entity's own stock
This comment letter provides our views on whether an instrument (or embedded feature) is indexed to an entity's own stock.

2 May 2008

Comment Letter - FASB Proposed FSP FAS 117-a-NFP endowments
This comment letter provides our views on the FASB's proposed FSP on endowments held by not-for-profits.

2 May 2008

Comment Letter - FASB Proposed FSP FAS 132R-a-pension disclosure matters
This comment letter provides our views on the FASB proposed FSP on pension disclosure matters.

31 March 2008

Comment Letter - Proposed FSP FAS 157-e and FSP FAS 115-a
This comment letter provides our views on the proposals that would change fair value and OTTI reporting.

31 March 2008

Comment Letter - Recommendations of SEC Advisory Committee on improvements to financial reporting
Recommendations of SEC Advisory Committee on improvements to financial reporting.

13 March 2008

Comment Letter - Proposed FSP SOP 90-7-a, An Amendment of AICPA Statement of Position 90-7
This comment letter provides our views on the proposed amendment of AICPA Statement of Position 90-7. This Sop related to entities undergoing reorganization or bankruptcy.

10 March 2008

Comment Letter - SEC proposal relating to internal control reporting for non-accelerated Filers
Focuses on SEC proposal relating to internal control reporting for non-accelerated filers.

10 February 2008

Comment Letter - Proposed changes to structure of the FASB
This comment letter provides our views on the Financial Accounting Federation's proposal to change the structure of the FASB and GASB.

18 January 2008

Comment Letter - Proposed FASB Staff Position No. FIN 48-b-effective date of FIN 48 for Nonpublic Enterprises
This comment letter provides our views about the effective date of FIN 48 for nonpublic companies.